NEWS20 February 2020

Google to move UK accounts to US

Brexit Europe GDPR Legal News North America Privacy Technology UK

US/UK – Google is planning to move its UK users’ accounts out of Ireland to the US in a move prompted by the UK’s departure from the European Union.

Google chrome_crop

According to Reuters, Google intends to require British users to acknowledge new terms of service, including the new US jurisdiction.

Google wants to move UK users out of Irish jurisdiction because it is unclear whether the UK will continue to follow the General Data Protection Regulation (GDPR), Reuters reported.

A Google spokesperson confirmed the company is moving its data controller relationship with the UK from Ireland to the US, but said UK users would still be covered by "UK GDPR".

The spokesperson said: "Like many companies, we have to prepare for Brexit. Nothing about our services or our approach to privacy will change, including how we collect or process data, and how we respond to law enforcement demands for users’ information. The protections of the UK GDPR will still apply to these users."

However, it is unclear what the UK’s data protection landscape will look like after the end of the Brexit transition period on 31st December 2020. Until then, GDPR will continue to apply in the UK.

According to the Information Commissioner’s Office (ICO) current guidance, the default position is the same as for a no-deal Brexit: the GDPR will be brought into UK law as the ‘UK GDPR’. However, this depends on the negotiations with the EU, which are due to begin next month.

Earlier this month, the prime minister said he wishes to develop a ‘separate and independent’ policy on data protection, and the government has said it will seek an adequacy agreement to allow personal data to continue to flow freely between the UK and the EU.

In California, where Google is headquartered, the California Consumer Privacy Act (CCPA) came into effect at the start of the year, and the US government is in the process of considering various pieces of federal data protection legislation including the Consumer Online Privacy Rights Act (Copra).